2016 (1) TMI 1493

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..... r the Assessee was justified in seeking the exclusion of CGL as a comparable. The ITAT has set out detailed reasons why the said plea of the Assessee was justified. Inter alia it was noticed that CGL s functional profile did not match that of the Assessee and a substantial portion of its earnings was on account of translation charges whereas the Assessee was not in that line of business at all. .....

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..... rt has, by an order dated 20 th October 2015 in ITA No. 813/2015, already dismissed the Revenue s appeal. He, however, seeks to distinguish the said case from the present one only on one aspect, i.e., the exclusion of M/s. Cosmic Global Ltd. ( CGL ) as a comparable by the Assessee before the ITAT, although the Assessee had itself included it at the stage of the proceedings before the Transfer Pri .....

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